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From: Brian Ashbrook [ mailto:Brian.Ashbrook@ormet.com ] Sent: Monday, July 08, 2013 10:41 AM To: Putney, David Subject: RE: section 114 testing

Mr. Putney,

Sorry for the delay in responding, but I was on vac ation last week.

I also apologize for the confusion on the submittal of the data. These problems will addressed quickl y.

Please call 740-483-2732 if there are additional qu estions.

Thanks,
Brian Ashbrook

From: Putney, David [ mailto:putney.david@epa.gov ] Sent: Tuesday, July 02, 2013 3:43 PM To: Brian Ashbrook Subject: RE: section 114 testing

Mr. Ashbrook,

During our review of the test data submitted for th e Ormet primary aluminum facility pursuant to the r ecent testing ICR, we have found several items for which we need additional information and/or clarification

. Specifically,

• It appears that we did not receive the test report associated with secondary potline emissions. The submitted reports (DAT Labs Cassette Analysis Repor t, ITT and cover letter to OEPA, and Ormet ICP PM-MCEM Mtl HAP – 2-13&App) do not appear to addres s secondary potline emissions. The file DAT Labs Cassette Analysis Report includes laboratory a nalyses of the cassettes, but not the emissions report. That is, we know the mass of pollutant capt ured in the cassettes, but not how to convert that to a lb of pollutant per ton of aluminum emission r ate.

• The aluminum production rates listed in Table 3-1 o n page 5 of the report (on the order of 260 tons per hour) appear VERY high. If you will supply a co rrected page 5 we can update the report before submitting it to the docket.

Note that in your earlier email you mentioned havin g trouble using the ERT. My contractor has not been able to locate an ERT report for your facility. If you d id submit such a report it may be that some of this requested information is in that report. Did you ever submit an ERT report for your facility – or was all data i ncluded in the 3 pdf files you initially submitted?p. 2 of 2

I also want to let you know that we have not finish ed reviewing the report yet, and we may have other questions in the future. We are trying to resolve questions as we find them instead of holding them u ntil the
end.

Thanks,

David Putney, Environmental Engineer U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Sector Policies and Programs Division 109 T.W. Alexander Drive, RTP, NC 27711 Mail Drop D243-02 Ph: (919) 541-2016 Fax: (919) 541-3207
Email: putney.david@epa.gov

From: Brian Ashbrook [ mailto:Brian.Ashbrook@ormet.com ] Sent: Friday, May 31, 2013 2:14 PM To: Putney, David Cc: psohi@aluminum.org Subject: section 114 testing

Mr. Putney,

I have attached the ITT for testing, the stack tes ting report, and the cassette testing report requir ed by Ormet Primary Aluminum to fulfill the section 114 request received by Ormet on March 11, 2013. I am having serious IT trouble with the ERT access program required by the EPA for submittal and I wanted to submit the da ta before the deadline. I will continue to work with our IT department to remedy this problem.

Please let me know if there is anything else I need to do.

Thanks,
Brian Ashbrook Environmental Services Manager Ormet Primary Aluminum Corporation
740-483-2732